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Privacy Policy

Introduction

At Toilet Twinning we are committed to keeping your data safe, and your privacy and peace of mind are important to us.

We only collect data from people for specific purposes, and once that purpose has finished, we won’t hold on to the data. We also won’t let anyone else access your data unless you’ve specifically asked us to.

This document tells you how, when and why we collect data from people, and what we use it for.

WHO WE ARE

Toilet Twinning is a water and sanitation charity initiative. We help those in desperate poverty to have access to a latrine, clean water, and the information they need to be healthy.

For the purposes of this policy, ‘us’, ‘we’ and ‘our’ refer to Toilet Twinning, which operates as part of Tearfund’s charity registration.

Tearfund is a charity registered in England and Wales (number 265464) and Scotland (SCO37624). Tearfund’s company number is 994339 and Tearfund’s registered office is at 100 Church Road, Teddington TW11 8QE.

WHEN AND HOW WE COLLECT INFORMATION

Directly with us

Firstly, and most obviously, when you give us your personal information, we save it and use it to communicate with you. Personal information means things like your name and contact details.

You send us this information when you make a donation, request materials or information, sign up for an event, provide comments or complete surveys.

When you visit our website

We collect non-personal data about people who visit our website. That’s things like IP addresses (which tell us, for example, the places where people are logging on), which pages people visit and which files they download. This helps us find out if our website is working well and helps us improve it. This information is collected using cookies – see the section on cookies below.

Information you put online

Sometimes we gather information that people make available on places like Twitter, Facebook or LinkedIn. You can check these organisations’ privacy policies to make sure you’re happy with how they handle your data.

Indirectly from third parties

If you give them your consent, we collect information from third parties such as event organisers (for example, a marathon organiser) or sites like Just Giving when you fundraise for Toilet Twinning. You can check their privacy policies to see how they handle your data.

Publicly available data

Sometimes we also collect publicly available information from Companies House, the Charity Commission and from articles, newspapers or blogs.

Sensitive data

If you send us sensitive information about yourself, for example about your religious beliefs, or your physical or mental health, please be aware that we may collect and keep this information unless you tell us not to. We will only keep this information where it is relevant to your interaction with us and we promise to keep it secure.

OUR BASIS FOR PROCESSING

If you engaged with us for the first time on or after 25 May 2018

We will only use your data in the ways you’ve asked us to.

You can change your preferences at any time – see the section ‘Your choices and telling us when things change’ below.

If you were an existing supporter before 25 May 2018

We will only email you if you have given consent. But we may also contact you by post or telephone if we have a legitimate reason to.

For example, if you make a donation we may send you information about how your donation is helping, or about other work we want to do. But we won’t contact you in this way if you’ve asked us not to. And you can change your preferences any time by contacting us by phone, post or email. See the section ‘Your choices and telling us when things change’ below.

Partnerships and major donors

If you show us you might be in a position to partner our work in a greater capacity, we will collect further information based on our legitimate interest. There are more details in the next section, ‘What do we do with it?’ This helps us recommend initial discussions with a relationship manager to supporters that might value it and ensure we use our supporters’ money in the most effective ways.

WHAT DO WE DO WITH IT?

Processing requests, Toilet Twinning actions and activities

We may use your personal data to:

process Twin Your Toilet requests and donations

support your fundraising for us, including Gift Aid, sending you the goods you have purchased, sending statements and invoices to you and collecting payments from you

keep you up-to-date on news and stories about our work

ask for financial support and non-financial support such as volunteering

process donations you give us, or to encourage your fundraising for us, including Gift Aid

provide information or packs, for example school packs you’ve asked for

provide a personalised service, such as customised website content or personalised emails

Personalised marketing

We might use your data to:

tell you about our work and how you can support our work, eg volunteering, community fundraising

deliver digital advertising about our work to you on social media websites such as Google and Facebook. We may also reach out to people who have similar interests to you. For example, we might use Facebook’s Custom Audience Programme. In this case, if you have agreed to receive email marketing communications from us, we send Facebook your email address. Facebook then delivers our advertising to you and to others with similar interests to yours. If you don’t have a Facebook account, Facebook just deletes the information. There are more details on Custom Audiences at Facebook Business, and you can read Facebook’s Privacy policy

help guide our marketing. For example, we will look at location and interests so we can invite you to a local event or tell you about an emerging need in an area you’re interested in.

understand whether you might want and be able to support us with a larger gift

approach you in your professional capacity, to talk about supporting our work

carry out market research

Partnerships and major donors

If you make a major gift to our work, we’ll offer you a relationship manager. They will discuss and agree with you how you want us to contact you. We will do this at the earliest convenient opportunity. If you don’t want to have a partnership relationship with us, we will destroy any additional, publicly sourced, personal data about you which we have collected for this purpose.

APPLYING FOR A JOB

An external company – Kingsley Management Consultancy Limited – provides our administration, fundraising and marketing at Toilet Twinning. When you apply for a job with us, the whole application, and any personal and sensitive information in it, all goes to them. This also includes all the personal information on your CV. They’ll keep and use this information to:

recruit for the role

make it easy for you to submit your CV online for jobs

answer your questions

do reference checks, qualifications checks, criminal referencing, service checks and verify your information. They’ll also use it for health screening and psychometric evaluation or skills tests. This is all done using third parties.

check we’re following our equal opportunities policy

HOW AND WHERE WE STORE YOUR INFORMATION

How long?

We keep your personal information only for as long as we need it for each activity. What we have to do by law, accounting and tax all come into play. We also have a separate data retention policy to guide us.

If you tell us you’re happy for us to send you marketing materials, we’ll keep contacting you for up to five years, unless you tell us not to. We decided on this length of time by asking our supporters what they thought.

If you have questions on any of this, or want to see the data retention policy, just get in touch:

Security

We do all we can to protect your personal data, and this includes having the right technology. For example, online forms are encrypted and our network is protected and regularly monitored.

The only people who can access personal data are Kingsley Management Consulting Limited (who do our administration, fundraising and marketing) and the Tearfund staff members or volunteers who can’t do their jobs without it. These people are all trained in data protection.

Occasionally we also use other external companies to help us with personal data tasks. We do checks on these companies, have them sign contracts, and keep checking them regularly. When we do use external companies, we are still the ones responsible for keeping your data safe.

But please remember, despite all of this, the internet is never 100 per cent secure. When you submit data, there is always a risk.

Credit / debit card security

We use PayPal and Stripe to handle all the payments we get through our website. We never keep people’s credit or debit card details, because that side of things is all done by Paypal and Stripe. You can read PayPal’s Privacy Policy for PayPal Services at Paypal.com and for more information on Stripe visit Stripe.com/gb/privacy.

Where we store your personal information

We use cloud-based systems to process data – that means data may be processed outside of the European Economic Area (EEA). We only let this happen when we believe your data will be kept safe. We do everything we can to make sure your data is looked after as described in this policy.

By giving us your personal data you’re agreeing to us using the cloud-based systems to process it.

WHEN WE SHARE YOUR INFORMATION

We want you to know that we don’t share or swap your information with any other charities for them to send you marketing. That decision is informed by our values and by how important your privacy is to us.

When we have to share information by law

We may need to pass on information if required by law or if a regulatory body, like HMRC, or the police ask us to.

Our service providers and third parties

We will only share information with PayPal or Stripe when they need it to process payments.

We use Kingsley Management Consultancy Limited to do administration for Toilet Twinning. This includes fulfilling orders, or processing orders or donations. Sometimes we also employ other agents to help with those tasks. They are bound by contract to protect your data and we are still the ones responsible for keeping your data safe.

Sometimes we give external companies information about the people using our website to help us make sure the website is working well and to find out how we can improve it. But this information is both anonymous and delivered in bulk. We’ll only use IP address information to identify someone if we feel they may cause safety/security issues, or if we have to give this information by law.

COOKIES

What are cookies?

Every time you visit our website, it sends us a cookie. Warm, crumbly and delicious? Sadly not. This is a text file that tells us about your visit. The information is all anonymous, so we’re told about your computer, not you. And when the data comes to us it’s bulked together with information from all the other visitors to our site. Cookies tell us, for example, about traffic data, location data, device information, the date and time people visit and the pages they visit.

How we use cookies on our website

To make the most of our website you should leave cookies turned on, otherwise you might not be able to see all of our lovely site.

Cookies help us:

customise what you see when you visit our site, and help us understand what would interest you

process any requests, applications or transactions

do our internal administration and analysis

Managing cookies

You can turn off cookies on most browsers. To find out how, use the help function.

Third party cookies

There are a few external companies that Toilet Twinning works with who set cookies on our website. PayPal and Stripe, who manage payments made to us online, will also send you cookies. Go to PayPal’s Privacy Policy for PayPal Services or Stripe.com for more information. The other external companies mainly help us with reporting and advertising so we can improve the way we communicate.

We use websites like Youtube and Vimeo to embed videos, and they may send you cookies too. We don’t control the setting of these cookies, so check those websites for more information.

Toilet Twinning also uses companies like Facebook, HotJar and Google Analytics, which may use cookies. They may also use tracking pixels, which tell us how effective our adverts are.

You can opt out of Google’s tracking cookies any time you want. Google uses cookies to match adverts with your preferences so they’re more relevant to you. If you don’t want to see adverts from us based on that information,you can use Google’s Ad Personalisation Tool.

All information we get through Google’s cookies is anonymous, it just helps us understand how people use our website and which pages are more popular. If you don’t want Google to include you in this information, you can install the Google Analytics Opt Out Tool.

As some of these services may be based outside of the UK and the European Union, they might not fall under the jurisdiction of UK courts. If you’re worried about that, you can change your cookie settings (see above). Or, for more information, visit https://ico.org.uk/

CHILDREN AND VULNERABLE PEOPLE

Aged 12 or under

Whenever we identify that a child is sending us their personal data, eg if they sign up for a school pack, or a community event, if they’re 12 or under, we’ll ask their parent or guardian to sign up on their behalf.

Supporters in vulnerable circumstances

We want to do all we can to support anyone we engage with who is in vulnerable circumstances. Our public-facing staff are all trained to identify signs of vulnerable circumstances and engage with the person in the right way. We have a separate vulnerable circumstances policy to guide us in this.

Information about the person will be recorded so we can respond appropriately in future, eg by no longer making fundraising requests or calls.

YOUR CHOICES AND TELLING US WHEN THINGS CHANGE

Preferences

If you want to change what we send you or how we contact you, just let us know – eg you can tell us you no longer want fundraising materials, or ask us to contact you by email rather than post.

Updating your details

Its really helpful if you keep your details with us up-to-date. Just get in touch and let us know if things change, using the same details (above).

Sometimes we use a Post Office address search or postcode lists etc to check data you send us. This could be when, for example, we are unsure of what address you’ve written on a form.

We won’t use these sources to gather information you haven’t given us, eg if you’ve left a telephone number blank. Nor will we automatically update changes of address – we will only update your address when you tell us it’s changed.

Your rights (for example, telling us to stop using your data)

At any time you can:

ask us to delete your personal data

limit how we keep and use your personal data

disagree with our reasons for keeping and using your personal data, eg where we have said we have a legitimate reason for processing it

disagree with personalised marketing, where we build up a profile of you (see the section on ‘What do we do with it?’ above). If you don’t want us to do this we might not be able to send you the information you’d find most interesting or useful.

ask us to give you an electronic copy of the information we have about you so you can send it to another organisation (data portability)

ask to see what information we have about you. We’ll respond within one month.

If you do want to do any of the above, just get in touch and let us know.

For more information about your rights under the General Data Protection Regulation, visit the Information Commissioner’s Office website at https://ico.org.uk.

CHANGES TO TOILET TWINNING’S PRIVACY AND SECURITY POLICY

Changes to this policy

We last updated this policy in May 2018. We’ll amend this policy if there are any changes to how we do things or changes to data protection or other legislation. If we make any significant changes we’ll show you clearly on our website, in our publications or by writing to you.

Whenever you engage with us through our websites, social media, email or telephone, or send us your personal information in any other way, we’ll process your information as explained in this policy. When you provide your information, you’re agreeing to this policy. If you don’t agree, please don’t give us your data.

You can also make a complaint about the use of your personal data with the Information Commissioners Office (ICO), the UK data protection regulator. You can do this by calling the ICO helpline or through the ICO website. For details, visit https://ico.org.uk/concerns/